Reviewing available information regarding the potential for products of forced labor, child labor, human trafficking and slavery to be present in its direct supply chain even though the raw materials used in the manufacture of architectural coatings are not known to be associated with any inhumane labor practices. It should be noted that architectural coatings raw materials are not among the products listed in U.S. Department of Labor's 2009 Report on the List of Goods Produced by Child Labor or Forced Labor. Further, the American Coatings Association, the principal trade association for the U.S. paint and coatings industry, is not aware of any documented instances of these labor practices in the industry or its supply chain. With respect to the sundry items sold but not manufactured by Benjamin Moore, there is no indication that our direct suppliers engage in any inhumane labor practices. Benjamin Moore has not conducted a third–party evaluation to verify this information.

If, at any time, Benjamin Moore should become aware of any credible indication of potential inhumane labor practices on the part of a direct supplier, we will arrange to audit that supplier to the extent practicable. Benjamin Moore does audit and monitor suppliers from time to time, but it does not conduct independent, unannounced audits.

Requiring its direct suppliers to certify in writing that materials incorporated into their products comply with the laws regarding forced labor, child labor, human trafficking and slavery in the country or countries where they do business

Training company employees and management who have direct responsibility for supply chain management on forced labor, child labor, human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.